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Privacy Policy

Last updated January 24th, 2025

Note on this English translation

This English version is provided for information purposes only. The German version is legally binding.

1. Introduction

Below, we provide information about the processing of personal data when using

  • our website www.hostzero.de
  • our website www.hostzero.com
  • our social media profiles

Personal data means all data that can be related to a specific natural person, e.g. their name or IP address.

1.1 Contact details

The controller within the meaning of Art. 4(7) of the EU General Data Protection Regulation (GDPR) is:

Hostzero GmbH
Möhnestraße 55
59755 Arnsberg
Germany
Email: info@hostzero.com

We are legally represented by Sven Völlmecke.

Our Data Protection Officer can be reached via:

heyData GmbH
Schützenstraße 5
10117 Berlin
www.heydata.eu
Email: datenschutz@heydata.eu

1.2 Scope of data processing, purposes of processing and legal bases

We set out the scope of processing, the purposes of processing and the legal bases in detail below. In principle, the following may be considered as legal bases for data processing:

  • Art. 6(1) sentence 1 lit. a GDPR serves as the legal basis for processing operations for which we obtain consent.
  • Art. 6(1) sentence 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. when a website visitor purchases a product from us or we provide a service for them. This legal basis also applies to processing that is necessary for pre-contractual measures, such as inquiries about our products or services.
  • Art. 6(1) sentence 1 lit. c GDPR applies if we fulfil a legal obligation by processing personal data, as may be the case in tax law, for example.
  • Art. 6(1) sentence 1 lit. f GDPR serves as the legal basis if we can rely on legitimate interests for processing personal data, e.g. for cookies that are necessary for the technical operation of our website.

1.3 Data processing outside the EEA

Insofar as we transmit data to service providers or other third parties outside the EEA, adequacy decisions of the EU Commission pursuant to Art. 45(3) GDPR ensure the security of the data during transfer, where such decisions exist, as is the case for the United Kingdom, Canada and Israel, for example.

When transferring data to service providers in the USA, the legal basis for the transfer is an adequacy decision of the EU Commission if the service provider has also been certified under the EU-US Data Privacy Framework.

In other cases (e.g. if no adequacy decision exists), the legal basis for the transfer is generally Standard Contractual Clauses, unless we provide different information. These are a set of rules adopted by the EU Commission and form part of the contract with the respective third party. Under Art. 46(2)(b) GDPR, they ensure the security of data transfers. Many providers have given additional contractual guarantees beyond the Standard Contractual Clauses that protect the data further. These include, for example, guarantees regarding encryption of the data or an obligation of the third party to notify data subjects if law enforcement authorities seek access to data.

1.4 Storage period

Unless expressly stated otherwise in this privacy policy, the data stored by us will be deleted as soon as it is no longer necessary for its intended purpose and no statutory retention obligations prevent deletion. If the data is not deleted because it is required for other legally permissible purposes, its processing will be restricted, i.e. the data will be blocked and not processed for other purposes. This applies, for example, to data that we must retain for commercial or tax law reasons.

1.5 Rights of data subjects

Data subjects have the following rights with regard to their personal data:

  • right of access,
  • right to rectification or erasure,
  • right to restriction of processing,
  • right to object to processing,
  • right to data portability,
  • right to withdraw consent at any time.

Data subjects also have the right to lodge a complaint with a data protection supervisory authority regarding the processing of their personal data. Contact details of the data protection supervisory authorities are available at https://www.bfdi.bund.de/DE/Service/Anschriften/Laender/Laender-node.html.

1.6 Obligation to provide data

Customers, interested parties or third parties only have to provide us with the personal data that is necessary to establish, conduct and terminate a business relationship or other relationship, or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude a contract or provide a service, or we will no longer be able to perform an existing contract or other relationship.

Mandatory information is marked as such.

1.7 No automated decision-making in individual cases

As a rule, we do not use fully automated decision-making pursuant to Art. 22 GDPR to establish and carry out a business relationship or other relationship. If we use such procedures in individual cases, we will inform you separately, insofar as this is required by law.

1.8 Contact

When contacting us, e.g. by email or telephone, the data provided to us (e.g. names and email addresses) will be stored by us in order to answer questions. The legal basis for processing is our legitimate interest (Art. 6(1) sentence 1 lit. f GDPR) in responding to inquiries addressed to us. We delete the data incurred in this context after storage is no longer necessary, or restrict processing if statutory retention obligations exist.

1.9 Customer surveys

From time to time, we conduct customer surveys in order to get to know our customers and their wishes better. In doing so, we collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so the legal basis for the associated processing is Art. 6(1) sentence 1 lit. f GDPR. We delete the data once the survey results have been evaluated.

2. Newsletter

We reserve the right to inform customers who have already used our services or purchased goods from us from time to time by email or by other means about our offers, provided they have not objected. The legal basis for this processing is Art. 6(1) sentence 1 lit. f GDPR. Our legitimate interest lies in direct marketing (Recital 47 GDPR). Customers can object to the use of their email address for advertising purposes at any time without additional costs, for example via the link at the end of each email or by email to the email address stated above.

On the basis of recipients’ consent (Art. 6(1) sentence 1 lit. a GDPR), we also measure the open rate and click rate of our newsletters in order to understand which content is relevant for our recipients.

We send newsletters using the CleverReach tool from CleverReach GmbH & Co. KG, Schafjückenweg 2, 26180 Rastede. The provider processes content data, usage data, meta/communication data and contact data in the EU. Further information is available in the provider’s privacy policy at https://www.cleverreach.com/de/datenschutz.

3. Data processing on our website

3.1 Information for website visitors from Germany

Our website stores information on the terminal equipment of website visitors (e.g. cookies) or accesses information that is already stored on the terminal equipment (e.g. IP addresses). The specific information involved can be found in the following sections.

This storage and access takes place on the basis of the following provisions:

  • Insofar as this storage or access is strictly necessary in order for us to provide the service of our website expressly requested by website visitors (e.g. to operate a chatbot used by a website visitor or to ensure the IT security of our website), it is carried out on the basis of Section 25(2) no. 2 of the Telecommunications Digital Services Data Protection Act (TDDDG).
  • Otherwise, this storage or access is carried out on the basis of the website visitors’ consent (Section 25(1) TDDDG).

Subsequent data processing is carried out in accordance with the following sections and on the basis of the provisions of the GDPR.

3.2 Informational use of the website

When the website is used for informational purposes, i.e. when visitors do not transmit information to us separately, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This constitutes our legitimate interest, so the legal basis is Art. 6(1) sentence 1 lit. f GDPR.

This data includes:

  • IP address
  • date and time of the request
  • time zone difference to Greenwich Mean Time (GMT)
  • content of the request (specific page)
  • access status/HTTP status code
  • amount of data transferred in each case
  • website from which the request comes
  • browser
  • operating system and its interface
  • language and version of the browser software

This data is also stored in log files. It is deleted when storage is no longer necessary, at the latest after 14 days.

3.3 Web hosting and provision of the website

We host our website ourselves and, in doing so, process the personal data accessed via the website, e.g. content data, usage data, meta/communication data or contact data. It is our legitimate interest to provide a website, so the legal basis for processing is Art. 6(1) sentence 1 lit. f GDPR.

It is our legitimate interest to provide a website, so the legal basis for the described processing is Art. 6(1) sentence 1 lit. f GDPR.

3.4 Contact form

If you contact us via the contact form on our website, we store the data requested there and the content of the message. The legal basis for processing is our legitimate interest in answering inquiries addressed to us. The legal basis for processing is therefore Art. 6(1) sentence 1 lit. f GDPR. We delete the data incurred in this context after storage is no longer necessary, or restrict processing if statutory retention obligations exist.

3.5 Job advertisements

We publish job advertisements on our website, on pages linked to the website, or on third-party websites. The data provided as part of the application is processed to carry out the application process. Insofar as this is necessary for our decision to establish an employment relationship, the legal basis is Art. 88(1) GDPR in conjunction with Section 26(1) of the German Federal Data Protection Act (BDSG). We have marked the data required to carry out the application process accordingly or refer to it. If applicants do not provide this data, we cannot process the application. Further data is voluntary and not required for an application. If applicants provide additional information, the basis is their consent (Art. 6(1) sentence 1 lit. a GDPR).

We ask applicants to refrain from providing information on political opinions, religious beliefs and similarly sensitive data in their CV and cover letter. This is not necessary for an application. If applicants nevertheless provide such information, we cannot prevent its processing as part of processing the CV or cover letter. In that case, processing is also based on the applicants’ consent (Art. 9(2) lit. a GDPR).

Finally, we process applicants’ data for further application processes if they have given us their consent to do so. In this case, the legal basis is Art. 6(1) sentence 1 lit. a GDPR.

We pass applicants’ data on to the responsible employees in the HR department, to our processors in the recruiting area, and to other employees involved in the application process.

If we enter into an employment relationship with the applicant after the application process, we delete the data only after termination of the employment relationship. Otherwise, we delete the data no later than six months after rejecting an applicant.

If applicants have given us consent to use their data for further application processes, we delete their data only one year after receipt of the application.

3.6 Third-party providers

3.6.1 Google reCAPTCHA

We use Google reCAPTCHA to manage authentications. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for processing is Art. 6(1) sentence 1 lit. a GDPR. Processing is carried out on the basis of consent. Data subjects can withdraw their consent at any time by, for example, contacting us using the contact details provided in this privacy policy. The withdrawal does not affect the lawfulness of processing up to the time of withdrawal.

The transfer of personal data to a country outside the EEA is based on an adequacy decision. The security of data transferred to the third country (i.e. a country outside the EEA) is ensured because the EU Commission has decided, in an adequacy decision pursuant to Art. 45(3) GDPR, that the third country provides an adequate level of protection.

Further information is available in the provider’s privacy policy at https://policies.google.com/privacy?hl=de.

4. Data processing on social media platforms

We are represented in social media networks in order to present our organisation and our services there. The operators of these networks regularly process their users’ data for advertising purposes. Among other things, they create user profiles from users’ online behaviour, which are used, for example, to display advertising on the network pages and elsewhere on the internet that corresponds to users’ interests. For this purpose, network operators store information about usage behaviour in cookies on users’ computers. It cannot be ruled out that the operators combine this information with other data. Users can find further information and instructions on how to object to processing by the platform operators in the privacy policies of the respective operators listed below. It is also possible that operators or their servers are located in non-EU countries and therefore process data there. This may result in risks for users, e.g. because enforcement of their rights is more difficult or public authorities may gain access to the data.

If users of the networks contact us via our profiles, we process the data provided to us in order to answer the inquiries. This constitutes our legitimate interest, so the legal basis is Art. 6(1) sentence 1 lit. f GDPR.

4.1 Facebook

We maintain a profile on Facebook. The operator is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://www.facebook.com/policy.php. A way to object to data processing is available via the ad settings: https://www.facebook.com/settings?tab=ads. On the basis of an agreement, we and Facebook are jointly responsible within the meaning of Art. 26 GDPR for processing the data of visitors to our profile. Which data is processed in detail is explained by Facebook at https://www.facebook.com/legal/terms/information_about_page_insights_data. Data subjects can exercise their rights both against us and against Facebook. Under our agreement with Facebook, however, we are obliged to forward requests to Facebook. Data subjects therefore receive a faster response if they contact Facebook directly.

4.2 Instagram

We maintain a profile on Instagram. The operator is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://help.instagram.com/519522125107875.

4.3 LinkedIn

We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy is available here: https://https://www.linkedin.com/legal/privacy-policy?_l=de_DE. A way to object to data processing is available via the ad settings: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

5. Changes to this privacy policy

We reserve the right to amend this privacy policy with effect for the future. The current version is available here in each case.

6. Questions and comments

If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact details provided above.